Interpretation Response #12-0182 ([ChemPura Pools, Ltd.] [Mr. David Brady])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 10/31/2012

Company Name: ChemPura Pools, Ltd.

Individual Name: Mr. David Brady

Location State: TX Country: US

View the Interpretation Document

Response text:

October 31, 2012

Mr. David Brady
ChemPura Pools, Ltd.
P.O. Box 56
586 Benjamins Way
Lewisville, TX 75067

Reference No. 12-0182

Dear Mr. Brady:

This is in response to your August 15, 2012 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to placarding requirements. Specifically, you ask what is the correct way to display placards on a motor vehicle under § 172.516(a).

You enclosed photographs that show a pair of adhesive-backed CORROSIVE (Class 8) placards displayed vertically on three sides and horizontally on the hood of a Chevrolet C1500 pickup truck. One placard has the word "CORROSIVE" printed in large letters across its center but does not have the number "8" in the bottom corner. The second placard has the UN number "1791" printed in large numbers across its center and the number "8" in the bottom corner. Your photographs also show the placards on the hood are placed with their bottom corners approximately three inches above the truck"s front grill on either side of the hood but just inside the area above the headlights. You state you placed the placards on the hood in this manner because placard holders were difficult to affix to the vehicle and simultaneously became a safety hazard and placard violation when they came off while travelling on a highway. You ask if the manner in which these placards are placed on the hood satisfies the requirement in § 172.516(a) of the HMR.

The answer is no. Section § 172.516(a) requires a placard to be clearly visible from the direction it faces, except from the direction of another transport vehicle to which it is coupled (see § 172.516(a)). The placards on the truck hood in the photographs you provided do not satisfy this requirement because their placement causes their designs to be
partially obscured when viewed a few feet in front of, or to the side of, the vehicle. Further, the placard with the word "CORROSIVE" printed in its center does not comply with the image of the CORROSIVE placard prescribed in § 172.558 because it is missing the number "8" in its bottom corner.

I hope this satisfies your request.

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

172.516

Regulation Sections